Professor Jim Stewart:

No, because it is not a matter of fact, it is a matter of opinion by the Revenue Commissioners. The Revenue Commissioners have looked at the facts and they have decided that the companies are not locating the subsidiaries for corporate tax purposes. Let us suppose that legislation is enacted, that the next Bill introduced in the Dáil will mean that a company is located in Ireland for corporate tax purposes, that means the €40 billion gets transferred into Ireland. We know that will not happen because companies will rearrange their corporate structure and it is likely - referring to the previous case I think companies had two years to organise their affairs - there will be a reallocation of the company structure and a reallocation of profits.

If one were to decide to end the current regime overnight, the profits in question would immediately transfer to Ireland.